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<br />CHAPTER IV
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<br />CONSULTATION AND COORDINATION
<br />COMMENT LETTERS
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<br />1993 JDL \ 7 I,M 9 56
<br />G.J,P.o.
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<br />HUTCHINS
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<br />1574 L Road
<br />Fruita, Colorado 81521
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<br />July 16, 1990
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<br />Ronald Johnston, Projects Manager
<br />Bureau of Reclamation
<br />2764 Compass Drive
<br />Grand Junction, CO 81506
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<br />Dear Mr. Johnston:
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<br />Thank you for the opportunity to comment on the Draft Environmental Assessment-Price and $Iubb Ditch
<br />Imorovements, Grand Valley Unit. Stage H, Colorado River Basin Salinity Control Project (CRaSe?) _
<br />Colorado River Water Quality Improvement Program, June 1990.
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<br />It is obvious by reviewing the evolution of the CRBSe?, Grand Valley Unit from its inception in 1974 to the
<br />present offering under consideration that the Bureau of Reclamation (BOR) is more than willing to
<br />negotiate, inveigle, and buy its way into agreements with entities singled out by the BOR to be participants
<br />in this Project
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<br />Numerous studies and reports have been authorized by the Environmental Protection Agency (EPA) and
<br />the BOR on salinity control. Studies such as the series of "The Best Management Practices..." etc. of the
<br />1970s were contracted by the EPA. The BOA published a multitude of works including the "Environmental
<br />Assessment" (EA), 19n, "Definite Plan Report" and "Draft Supplement to the Definite Plan Report," 1983,
<br />"Salt Pickup Calculations Draft Report," 1983, the "Draft Environmental Impact Statement," 1985, "The Rnal
<br />Environmental Impact Statement" (FEIS), 1986, "Verification Memorandum" (VM), 1986, the "Water
<br />Resource Technical Supporting Data for the Verification Memorandum," 1986, and the current "Draft
<br />Environmental Assessment, Price and Stubb Improvements" (DEA), 1990.
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<br />These works evidence the continual flux, uncertainty, and manipulation of the figures being used by the
<br />BOR to support the salinity control project.
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<br />The Grand Valley Unit's FEIS omits and does not consider lining private canals because it was determined
<br />through studies not to be cost effective.
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<br />This Draft EA asserts it has become cost efficient to line two private canal reaches: the Stubb and Price
<br />Canals. Construction costs are assumed to be a total of $9,086,300.
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<br />Comment:
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<br />Chapter 11, page 4, "Recommended Plan," Table 1.
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<br />This table shows the following: the incremental cost effectiveness of lining the Price Ditch
<br />is $43/100 of salt removed and the cost effectiveness of piping the Stubb Ditch is $49/ton
<br />of salt removed. The total length of the Stubb Ditch to be piped is 10.2 mlles and the tolal
<br />length 01 the Price Ditch to be lined is 9.1 miles. These distances comprise the total length
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